For the purposes of the Data Protection Act 1988 (the Act), the data controller is The Social Travel Club Limited. We are a limited company registered in England and Wales under company number 07031138 and have our registered office at Lansdell & Rose, 36 Earls Court Road, London, W8 6EJ, England. Our main trading address is 81 Rivington Street, London, EC2A 3AY, England.
1. Information we may collect from you
We may collect and process the following data about you:
· Information you give to us. You may give us information about you by filling in forms on the Website or by corresponding with us by phone, email or otherwise. This may include, without limitation, information you provide when you use the Website, register as a member, subscribe to and use our service, post material, search for a property on the Website, request further information or services from us, request information from other members, make use of any interactive features on the Website, enter a competition or promotion or complete a survey and/or when you report a problem with the Website. The information you give us may include, without limitation, your name, address, email address, phone number and photographs, as well as financial and credit card information. If you contact us for any reason, we may keep a record of that correspondence.
· Information we collect about you. Each time you visit the Website, we may automatically collect and process certain technical information (this is statistical data about our users' browsing actions and patterns and does not identify any individual), as well as certain information about your visit to the Website (including items you viewed or searched for, page response times, download errors, length of visits to certain pages and page interaction information).
· Information we receive from other sources. We may receive information about you if you use any of the other websites we operate, or the other services we provide, from time to time. We may also receive information about you from third parties if you use any websites or social media platforms operated by third parties (for example, Facebook, Twitter, Instagram, etc.) and, if such functionality is available, you have chosen to link your profile on the Website with your profile on those websites or other social media platforms. We may also work closely with other third parties (including, for example and without limitation, business partners, subcontractors in technical and payment services, advertising networks, analytics providers, search information providers and credit reference agencies) and may receive information about you from them.
2. Use made of the information
We will not sell or license any personal information about you to any third party. We use information held about you in the following ways:
· Information you give to us. We will use this information: (i) to carry out our obligations arising from any contracts entered into between us and you and any relevant third parties and to provide you with the information and services that you request from us; (ii) to facilitate any transactions on the Website offered and/or administered by third parties in which you choose to participate; (iii) to pass any feedback and/or comments you provide via the Website to the third parties in respect of whom the feedback and/or comments were given; (iv) to provide you with information about us and to send you newsletters and other relevant information; (v) to provider you with information about other services we offer that are similar to those that you have already made use of or enquired about; (vi) to provide you, or permit selected third parties to provide you, with information about products and/or services we feel may be of interest to you. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please contact us at firstname.lastname@example.org; (vii) to notify you about changes to our service; and (viii) to ensure that content from the Website is presented in the most effective manner for you and for your computer.
· Information we collect about you. We will use this information: (i) to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; (ii) to improve the Website and to ensure that content from the Website is presented in the most effective manner for you and for your computer; (iii) to allow you to participate in any interactive features on the Website, when you choose to do so; (iv) as part of our efforts to keep the Website safe and secure; (v) to measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising to you; and (vi) to make suggestions and recommendations to you and other users of the Website about products and/or services that may interest you or them.
· Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
3. Disclosure of your information
We may share your information with any member of our group from time to time, which means our subsidiaries, our ultimate holding company and its subsidiaries, in each case as defined in section 1159 of the UK Companies Act 2006 (as amended from time to time).
We may also share your information with selected third parties, including: (i) other members and users of our service; (ii) business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you; (iii) advertisers and advertising networks that require the data to select and serve relevant adverts to you and others (although we will not disclose information about identifiable individuals to our advertisers); and (iv) analytics and search engine providers that assist us in the improvement and optimisation of the Website.
We may disclose your personal information to third parties: (i) if The Social Travel Club Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users and members may be one of the transferred assets; and (ii) if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, or in order to enforce or apply our Service Terms and Conditions or any other agreements; or to protect the rights, property or safety of The Social Travel Club Limited, our members or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and with law enforcement agencies or court officials.
4. Management of your profile and personal information
If you register as a member of our service, you will control your user profile. This means that you will be able to access your details by going to your profile page on the Website where you may review, correct and/or update the majority of your information at any time.
If you terminate or cancel your membership, we will remove your listings from the Website as soon as is reasonably possible. However, we reserve the right to retain certain information about your listings, communications and account in order to enforce our Service Terms and Conditions, analyse user experiences to improve our business and resolve disputes. Members should not expect that all their personal information will be removed from our databases after termination or cancellation of their membership.
For answers to frequently asked questions about how our Social Circle feature works with Facebook, please see here.
5. Your use of other members' personal information
We do not ordinarily share the identity, address or email
address or other contact details of members with other members;
instead, we facilitate communications between members through a
messaging system on the Website. However, members may of course
communicate their contact details to other members in connection
with their use of our service.
Circumstances may also arise when one member may have an urgent need to contact another member and, in those circumstances, we may, at our sole and absolute discretion, provide a member's contact information to another member.
You agree that you will only use other another member's personal information obtained through us: (i) to make arrangements in connection with your use of our service; and (ii) for any other purpose to which the other member expressly agrees after complete disclosure of the purpose.
Under no circumstances will you disclose another member's personal information to any third party without the express consent of that member.
6. Where we store your personal data and data security
All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using secure technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is never completely private or secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any of your data transmitted to the Website and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, misuse or loss.
(together referred to herein as cookies) to distinguish you from
other users of the Website. This helps us to provide you with a
good experience when you browse the Website and also allows us to
improve the Website.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device, if you agree. Cookies contain information that is transferred to your hard drive.
We may use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily. All information collected by these cookies is aggregated and, therefore, anonymous.
• Functionality cookies. These are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. All information collected by these cookies is aggregated and, therefore, anonymous.
You can find more information about some of the individual cookies we currently use and the purposes for which we use them in the table below:
|Facebook Connect||Widgets, Social||http://www.facebook.com/about/privacy/||Data Collected: Anonymous (Browser Information, Date/Time, Demographic Data, Hardware/Software Type, Page Views ) Pseudonymous (IP Address (EU PII)) Data Sharing: Anonymous data is shared with 3rd parties. Data Retention: Undisclosed|
|Google AdWords Conversion||Advertising||http://www.google.com/intl/en/policies/privacy/||Data Collected: Anonymous (Ad Views, Analytics, Browser Information, Cookie Data , Date/Time, Demographic Data, Hardware/Software Type, Interaction Data , Page Views , Serving Domains) Pseudonymous (IP Address (EU PII), Search History, Location Based Data, Device ID (EU PII)) PII (Phone Number) Data Sharing: Anonymous data is shared with 3rd parties. Data Retention: Undisclosed|
|Google Analytics||Analytics||http://www.google.com/intl/en/policies/privacy/||Data Collected: Anonymous (Ad Views, Analytics, Browser Information, Cookie Data , Date/Time, Demographic Data, Hardware/Software Type, Interaction Data , Page Views , Serving Domains) Pseudonymous (IP Address (EU PII), Search History, Location Based Data, Device ID (EU PII)) PII (Phone Number) Data Sharing: Undisclosed Data Retention: Undisclosed|
|Google+ Platform||Widgets, Social||http://www.google.com/intl/en/policies/privacy/||Data Collected: Anonymous (Ad Views, Analytics, Browser Information, Cookie Data , Date/Time, Demographic Data, Hardware/Software Type, Interaction Data , Page Views , Serving Domains) Pseudonymous (IP Address (EU PII), Search History, Location Based Data, Device ID (EU PII)) PII (Phone Number) Data Sharing: Anonymous data is shared with 3rd parties. Data Retention: Undisclosed|
|Optimizely||Beacons, A/B Testing, Site Optimization||http://www.optimizely.com/privacy||Anonymous (Analytics, Browser Information, Interaction Data , Page Views ) Pseudonymous (IP Address (EU PII), Clickstream Data) Data Sharing: Anonymous data is shared with 3rd parties. Data Retention: Undisclosed|
|Pingdom||Beacons||https://www.pingdom.com/legal/privacy-policy/||Data Collected: Undisclosed Data Sharing: Undisclosed Data Retention: Undisclosed|
|Twitter Button||Widgets, Social||https://twitter.com/privacy||Data Collected: Anonymous (Browser Information, Cookie Data , Date/Time, Demographic Data, Hardware/Software Type, Internet Service Provider, Interaction Data , Page Views ) Pseudonymous (IP Address (EU PII), Search History, Device ID (EU PII)) Data Sharing: Aggregate data is shared with 3rd parties. Data Retention: 18-24 Months|
|Typekit by Adobe||Widgets, Font System||http://www.adobe.com/privacy/typekit.html||Data Collected: Anonymous (Serving Domains) Data Sharing: Undisclosed Data Retention: Undisclosed|
|ValueClick Mediaplex||Advertising||http://www.conversantmedia.com/legal/privacy||Data Collected: Anonymous (Ad Views, Browser Information, Date/Time, Hardware/Software Type, Interaction Data , Page Views , Serving Domains) Pseudonymous (IP Address (EU PII), Search History, Clickstream Data) Data Sharing: Anonymous data is shared with 3rd parties. Data Retention: 18-24 Months|
|DoubleClick Floodlight||Beacons, Tag manager, Analytics||http://www.google.com/intl/en/policies/privacy/||Data Collected: Anonymous (Ad Views, Analytics, Browser Information, Cookie Data , Date/Time, Demographic Data, Hardware/Software Type, Interaction Data , Page Views , Serving Domains) Pseudonymous (IP Address (EU PII), Search History, Location Based Data, Device ID (EU PII)) PII (Phone Number) Data Sharing: Anonymous data is shared with 3rd parties. Data Retention: Undisclosed|
You can block the download of all or some cookies or remove/disable them (including the cookies we use) by altering the privacy settings on your web browser. Guidance on how to do this can be found at http://cookiepedia.co.uk/. However, if you use your browser settings to block all or some cookies (including essential cookies), you may not be able to access all or parts of the Website.
You can also prevent your data from being used by Google Analytics by downloading and installing the Google Analytics opt out browser add-on. Guidance on how to do this can be found at https://tools.google.com/dlpage/gaoptout/.
8. Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing (i.e. to opt out of receiving any marketing communications) at any time by contacting us at email@example.com.
The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
9. Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
11. Contact details
3 June 2015